Should a Person Who Reports Illegal Activity Be Protected ?

In Palmateer v. International Harvester Company, 85 Ill. 2d 124, 421 N.E.2d 876, 52 Ill. Dec. 13 (1981), the court expanded the tort to protect "whistle-blowers," i.e. those who report illegal or improper conduct. The plaintiff in Palmateer claimed That he was fired for reporting a possible criminal violation by a coworker and agreeing to cooperate with the police in the investigation of the alleged violation. The court held that public policy protected the "citizen crime fighter." Palmateer, 85 Ill. 2d at 132, 421 N.E.2d at 880. The court reasoned: "There is no public policy more basic, nothing more implicit in the concept of ordered liberty [citation], than the enforcement of a State's criminal code. There is no public policy more important or more fundamental than the one favoring the effective protection of the lives and property of citizens." Palmateer, 85 Ill. 2d at 132-33, 421 N.E.2d at 879. Accordingly, the court held, an employee should be able to report illegal activity without fear of discharge. Palmateer, 85 Ill. 2d at 132, 421 N.E.2d at 879.